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TANF Work Participation Is Measured Consistently across States' which
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Report to the Chairman, Subcommittee on Human Resources, Committee on
Ways and Means, House of Representatives:
United States Government Accountability Office:
GAO:
August 2005:
Welfare Reform:
HHS Should Exercise Oversight to Help Ensure TANF Work Participation Is
Measured Consistently across States:
GAO-05-821:
GAO Highlights:
Highlights of GAO-05-821, a report to the Chairman, Subcommittee on
Human Resources, Committee on Ways and Means, House of Representatives:
Why GAO Did This Study:
The debate over reauthorization of the Temporary Assistance for Needy
Families (TANF) block grant has focused on work requirements and
brought attention to the measure of TANF work participation. The
measure is used to assess statesí performance and determine whether a
state is subject to penalty for not meeting TANF work requirements. The
2003 work participation rates ranged from 9 to 88 percent for the 50
states based on data they submit to the U.S. Department of Health and
Human Services (HHS). To help Congress understand these rates, GAO
looked at (1) how selected states are defining the categories of work
activities, (2) whether selected states have implemented internal
controls over the work participation data, and (3) what guidance and
oversight HHS has provided states.
What GAO Found:
Differences in how states define the 12 categories of work that count
toward meeting TANF work participation requirements have resulted in
some states counting activities that other states do not count and,
therefore, in an inconsistent measurement of work participation across
states. For example, 5 of the 10 states we reviewed considered caring
for a disabled household or family member to count toward the federal
work participation requirement, while 5 did not consider hours spent in
this activity to be countable (see table below). We also found that
some states made significant changes in their definitions of the
categories of work. As a result, the work participation rates for these
states cannot be compared from year to year.
Some of the states in our review have implemented internal controls to
help report work participation hours in accordance with HHS guidance,
while other states lack such internal controls. Some states have not
issued guidance on how to verify that reported hours were actually
worked, nor do they monitor data reported by their staff to help ensure
that hours are reported correctly. In contrast, a few states have
systematic approaches for verifying that hours reported were worked.
HHS has provided limited oversight and guidance to states on
appropriately defining work activities and reporting hours of work
participation. According to HHS officials, HHS has the authority to
regulate statesí definitions of work activities. However, to promote
state flexibility, HHS chose not to issue regulations for this purpose.
Further, HHSís guidance lacks specific criteria for determining the
appropriate hours to report. Given that HHS has not exercised oversight
of statesí definitions and internal controls, states are making
different decisions about what to measure. Therefore, there is no
standard basis for interpreting statesí rates, and the rates cannot
effectively be used to assess and compare statesí performance.
Number of Reviewed States that Count Certain Activities toward Meeting
the Federal Work Participation Rate and the Categories of Work in Which
the States Counted the Activities
[See PDF for image]
Source: GAO review of 10 statesí TANF documents and interviews with the
statesí TANF officials.
Note: An additional state counts substance abuse treatment, domestic
violence counseling, and other mental health counseling toward meeting
the federal work participation rate in limited circumstances.
[End of table]
What GAO Recommends:
GAO recommends that HHS enact regulations to provide oversight of
statesí definitions and more guidance on counting hours of work
activities and that HHS identify cost-effective internal control
practices and disseminate information on these practices to states. In
commenting on our draft report, HHS said it would consider making the
recommended revisions in its regulations after TANF reauthorization and
is exploring options for implementing the recommendation on internal
controls.
www.gao.gov/cgi-bin/getrpt?GAO-05-821.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact David Bellis at (415) 904-
2272 or bellisd@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Differences in How States Define Work Activities Result in Inconsistent
Measurement of Work Participation across States and over Time:
Some States Do Not Have Internal Controls Needed for Reporting Data in
Accordance with HHS Guidance, while Other States Do:
HHS's Oversight and Guidance on Appropriately Defining Work Activities
and Reporting Hours of Work Participation Have Been Limited:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Elements of the Work Participation Requirement and How the
Work Participation Rate Is Calculated:
Appendix II: States That Count Certain Activities toward Meeting the
Federal Work Participation Rate:
Appendix III: States Identified as Lacking Certain Internal Controls:
Appendix IV: Fiscal Year 2003 Work Participation Rates Calculated by
HHS Based on Data Provided by States:
Appendix V: Comments from the Department of Health and Human Services:
Appendix VI: GAO Contact and Staff Acknowledgments:
Related GAO Products:
Tables:
Table 1: 12 Categories of Federal Work Activities and Limitations on
Counting Time in Those Activities:
Table 2: The Number of 10 Reviewed States That Count Certain Activities
toward Meeting the Federal Work Participation Rate and the Categories
of Work in Which the States Counted the Activities:
Table 3: Number of Reviewed States Lacking Internal Controls to Help
Ensure Hours of Participation Are Reported in Accordance with HHS
Guidance:
Table 4: Number of Hours Different Types of Recipients Must Participate
in Allowed Work Activities to Count as Working in the TANF All-Family
Work Participation Rate:
Table 5: Base Percentage of TANF Families That Must Be Engaged in Work
for the All-Family and the Two-Parent Family Rates:
Table 6: States Covered by the Review That Count Certain Activities
toward Meeting the Federal Work Participation Rate:
Table 7: States Covered by the Review That Lacked Internal Controls to
Help Ensure Hours of Participation Are Reported in Accordance with HHS
Guidance:
Table 8: Fiscal Year 2003 Work Participation Rates Calculated by HHS
Based on Data Provided by States:
Figure:
Figure 1: Formula for Calculating the All-Family Work Participation
Rate:
Abbreviations:
ACF: Administration for Children and Families:
HHS: U.S. Department of Health and Human Services:
MOE: maintenance-of-effort:
NDNH: National Directory of New Hires:
OMB: Office of Management and Budget:
PRWORA: Personal Responsibility and Work Opportunity Reconciliation Act
of 1996:
SSP: separate state program:
TANF: Temporary Assistance for Needy Families:
United States Government Accountability Office:
Washington, DC 20548:
August 19, 2005:
The Honorable Wally Herger:
Chairman:
Subcommittee on Human Resources: Committee on Ways and Means:
House of Representatives:
Dear Mr. Chairman:
In fiscal year 2004, states spent $26 billion from the federal
Temporary Assistance for Needy Families (TANF) block grant and related
state funds to assist low-income parents and their children. The
federal welfare reform law--the Personal Responsibility and Work
Opportunity Reconciliation Act of 1996 (PRWORA)--that created the TANF
block grant included the expectation that welfare recipients would
participate in work activities. The law outlined 12 categories of work
activities, such as "unsubsidized employment" and "community service
programs," in which recipients could participate to meet federal TANF
requirements. Under the law, states have significant flexibility in
designing their TANF programs, such as flexibility in defining specific
activities to fall under the 12 categories of work activities outlined
in the law. Along with providing this flexibility, PRWORA required
states to collect and report a specified set of data to the Department
of Health and Human Services (HHS), including data on hours recipients
spent in work activities. PRWORA also created a performance measure
called the TANF work participation rate for determining the extent to
which a state's TANF families were engaged in work activities during
the year. The 2003 work participation rates calculated for the 50
states based on the data they submitted to HHS ranged from 9 to 88
percent. HHS is responsible for reporting these rates to Congress and
for using them to identify states that are not meeting the required
level of work participation for their TANF recipients and, thus, may be
subject to penalties. Given the importance of the work participation
rates, they need to provide a consistent measure of work participation
across states. Without a consistent measure, there will be no standard
basis for interpreting each state's rate or for comparing the
performance of states.
A key issue in the debate over TANF reauthorization has been whether to
change work requirements, such as by requiring additional hours of work
and allowing more types of work activities to be counted. For example,
a Senate bill proposed adding substance abuse treatment and caring for
a disabled family member to the list of activities that can be counted
as work participation. Another issue in reauthorization has been how to
revise the caseload reduction credit, which uses levels of TANF
caseload declines to reduce the work participation rates states must
have in order to avoid penalty. Because of significant declines in TANF
caseloads following TANF implementation, the caseload reduction credit
enabled many states to have very low work participation rates and still
meet their required levels of work participation. Revisions in the
caseload reduction credit could raise the required level of work
participation for many states and may result in more states being
penalized for not having high enough work participation rates. In
considering welfare reauthorization, Congress has focused much
attention on states' current work participation rates. To help you
understand these rates, we looked at (1) how selected states are
defining the work activities that count toward meeting federal work
participation requirements, (2) whether selected states have
implemented internal controls to help ensure that the work
participation data they report are in accordance with HHS guidance, and
(3) what guidance and oversight HHS has provided states regarding
appropriately defining work activities and reporting hours of work
participation.
Our review focused on HHS's Administration for Children and Families
(ACF), which administers the TANF block grant, and 10 selected states--
California, Georgia, Kansas, Maryland, Nevada, New York, Ohio,
Pennsylvania, Washington, and Wisconsin. In 2003, the 10 states made up
46 percent of the national TANF caseload. We selected these states to
represent a mix of TANF 2003 work participation rates, according to
data reported by states to ACF.[Footnote 1] (These rates are shown in
app. IV.) Specifically, we selected the 3 states with the lowest rates
(9 percent to 11 percent), 3 states with some of the highest rates (62
percent to 88 percent), and 4 states with rates in the middle range (22
percent to 46 percent). We also selected states to represent a variety
of other characteristics, such as geographic location, benefit
policies, and use of waivers that exempt the state from certain TANF
requirements. We used a semistructured interview protocol in conducting
telephone interviews with the 10 selected states' TANF officials.
To learn how selected states are defining the work activities that
count toward meeting federal work participation requirements, we
interviewed the 10 selected states' TANF officials about activities
they count in work participation data. We also reviewed state
documents, such as annual TANF reports and TANF manuals that show how
states define the 12 federal categories of work activities and how they
classify recipients. Although our work allowed us to identify
inconsistencies in definitions and classifications across states, we
did not have data to evaluate the impact of different definitions and
classifications on the rates.
To learn whether selected states have implemented internal controls to
help ensure the work participation data they report are in accordance
with HHS guidance, we interviewed the 10 selected states' TANF
officials about their internal controls over collection and reporting
of the data. We also reviewed the states' guidance on collection and
reporting of the data.[Footnote 2] Through these telephone interviews
and document reviews, we learned about policies and processes
established by the states to help ensure data reported are in
accordance with HHS guidance, but we could not learn whether these
policies and processes are effectively carried out by staff at the
local level. Also for the 10 states, we interviewed state auditors and
reviewed single audit reports for fiscal years 2000-2003 and any other
state audit reports that addressed work participation data.
To learn what guidance and oversight HHS has provided states regarding
appropriately defining work activities and reporting hours of work
participation, we interviewed ACF officials about their oversight of
states' definitions of work activities that count toward the work
participation rates and states' data on hours of work participation. We
also interviewed officials from the HHS Office of Inspector General. In
addition, we reviewed ACF's regulations and other guidance for
reporting work participation data. We conducted our work from November
2004 to June 2005 in accordance with generally accepted government
auditing standards.
Results in Brief:
Differences in how states define the 12 categories of work that count
toward meeting federal work participation requirements have resulted in
some states counting activities that other states do not count and,
therefore, in an inconsistent measurement of work participation across
states. For example, out of the 10 states we reviewed, 5 considered
caring for a disabled family or household member to be part of the
Community Service category of work activities, but 5 other states
considered this activity as not countable. Also, 6 of the 10 selected
states considered substance abuse treatment to be part of countable
categories such as Job Search/Job Readiness, Work Experience, and
Community Service, but 4 states did not consider it a countable
activity. We also found that some states made significant changes year
to year in which activities they count in the work participation rate.
As a result, the rates for these states cannot be compared from year to
year to assess how the states' performance changed. For example, after
expiration of a waiver that had exempted it from restrictions on time
spent in Job Search/Job Readiness, one state redefined many activities
from Job Search/Job Readiness to other categories without time
restrictions. After this change, the state's work participation rate
calculated based on nonwaiver requirements increased more than 50
percentage points. Another inconsistency among states--which adult
recipients are counted in work rates--occurs because states have
flexibility in how they classify recipients. Four of the 10 states have
used their funding flexibility to serve two-parent families through
separate state-funded programs not covered by TANF work requirements,
and 1 state also served adults with significant barriers, such as
medical problems, through a separate state program. Thus, in these
states, all of these cases were removed from the work participation
rate calculation, while these types of cases are included in other
states' rate calculations.
In reviewing the 10 states' internal controls for collecting and
reporting hours TANF recipients spent in work activities (regardless of
how the states defined the activities), we found that some states have
implemented internal controls to help report work hours in accordance
with HHS guidance, while other states are lacking such internal
controls. For example, some states have not issued guidance for their
staff on the support needed to verify that reported hours were worked.
As a consequence, some states report hours that recipients are
scheduled to work instead of hours actually worked, especially in the
case of unsubsidized employment, for which, according to state
officials, it is difficult to get documentation from employers and
recipients to verify hours worked. Two states have guidance allowing
hours that were missed to be reported as worked when case workers
determine that the recipient had good cause for the absence. One
state's guidance instructs that 30 hours of participation per week be
reported for certain activities such as a parent's involvement in her
child's Head Start program but does not require evidence that the
parent was actually involved in 30 hours of the activity. In contrast,
a few of the 10 states had systematic approaches for verifying that
hours reported were worked. For example, according to officials in some
states, their states review the documentation in each sampled file to
ensure that hours reported are supported before submitting their data
to HHS.
HHS has provided limited oversight and guidance to states on
appropriately defining work activities and reporting hours of work
participation. According to HHS officials, HHS has authority under
PRWORA to regulate states' definitions of work activities. However, HHS
has chosen not to issue regulations for this purpose in order to
promote the flexibility PRWORA provided states and in response to calls
from states for as much flexibility as possible in designing their TANF
programs, according to HHS officials. The current TANF regulations
repeat the 12 categories of work activities that are included in PRWORA
and do not further specify activities that can and cannot be included
under the 12 categories. Given the current regulatory structure, HHS
officials said they cannot direct states to change their definitions if
HHS believes the definitions are inappropriate. HHS's guidance on the
appropriate hours to report is also limited. HHS has specified in TANF
regulations that the quarterly reports that contain work participation
data be "complete and accurate." In other guidance, HHS has further
specified that states must report "actual" hours that recipients engage
in work activities rather than hours for which the recipient is
scheduled or expected to work. However, the guidance does not specify
what support is needed to verify actual hours of work participation.
HHS performs checks on the data that can identify inconsistencies but
cannot determine whether hours reported were actually worked. According
to HHS officials, HHS's primary mechanism for identifying states that
are not reporting data in accordance with HHS guidance is the state
single audits that review internal controls and compliance with laws
and regulations governing federal awards. Although HHS has identified
data problems using state single audit reports, some of the internal
control problems we identified in this review had not been found by
single audits. To emphasize the importance of work participation data,
HHS is adding to the single audit guidance for fiscal year 2005 more
instructions on reviewing work participation data.
To help improve the quality and comparability of the work participation
data, we are recommending that HHS issue regulations to provide
oversight of states' definitions and more guidance on counting hours of
work activities and that HHS work with states to identify cost-
effective internal control practices and disseminate information on
these practices to states.
In commenting on our draft report, HHS said it would consider making
the recommended revisions in its regulations after TANF reauthorization
and is exploring options for implementing the recommendation on
internal controls.
Background:
Enactment of the TANF block grant significantly changed federal welfare
policy and gave states more flexibility in designing their welfare
programs. For example, states have flexibility in setting benefit
levels, eligibility requirements,[Footnote 3] work requirements, and
policies for sanctioning noncompliant recipients (that is, reducing or
discontinuing their benefits). Due to this flexibility, TANF programs
differ substantially from state to state. These different state
policies can affect the extent to which a state's TANF recipients
participate in work activities and the type of work activities they
engage in. States also have flexibility in using TANF block grant funds
and in using state funds--referred to as maintenance-of-effort (MOE)
funds--that states were required to use toward TANF purposes in order
to qualify for the block grant. For example, if states want to
exclusively use MOE funds for a particular group of welfare recipients,
such as those in two-parent families, they can use these funds through
separate state programs (SSPs) for those recipients and remove them
from the TANF requirements.
Due to the importance of state flexibility under TANF, PRWORA limited
HHS's authority to regulate state TANF programs. PRWORA also
substantially reduced HHS staff available to implement TANF. However,
PRWORA established penalties for states, such as for not meeting
required levels of work participation, and HHS has authority to
regulate in situations where penalties are involved. TANF has two work
participation rates--one that applies to all adult-headed families and
another that applies to two-parent families.[Footnote 4] A certain
percentage of each state's adult-headed TANF cases receiving cash
assistance must participate in work-related activities for a minimum
number of hours each week or the state may face financial
penalty.[Footnote 5] The categories of work activities that can be
counted for the purpose of the performance measure are outlined in TANF
law and regulations. If TANF recipients engage in other activities
provided or permitted under the state's TANF program, then those
activities do not count toward meeting the federal work participation
requirements. Further, if TANF recipients engage in work activities for
less than the minimum required number of hours, then those recipients
do not count as being engaged in work for purposes of the performance
measure.
When a state does not meet its required level of work participation,
HHS will send the state a penalty notice. The state then has the
opportunity to avoid a penalty by providing reasonable cause why it did
not meet the work participation rate or by submitting a corrective
compliance plan that will correct the violation and ensure continued
compliance with work participation requirements. Since implementation
of TANF, numerous states have received penalty notices from HHS for not
meeting the required level of work participation. However, most of
these states have avoided penalties by submitting corrective compliance
plans. As of February 2005, 11 states[Footnote 6] and the District of
Columbia had paid penalties for not meeting the two-parent work
participation rate.[Footnote 7] Most of these penalties were for the
first 4 years (fiscal years 1997-2000) of TANF implementation, and 5
states and the District of Columbia have paid penalties for more than 1
year.
Each quarter, states are required to report to ACF monthly data on
their TANF cases, including the number of hours each adult recipient
spent in activities that count toward meeting federal work
requirements. States have the option of reporting to ACF on all their
TANF cases (the universe) or on a scientifically drawn sample of TANF
cases. Using the data reported by states, ACF calculates an annual work
participation rate for each state. A state's annual work participation
rate is based on the state's average monthly rate for the year. See
appendix I for information on elements of the work participation
requirement and how the work participation rate is calculated by ACF.
12 Categories of Countable Work Activities:
The TANF legislation and regulations outline 12 categories of work
activities that can count toward the federal work requirement. The TANF
regulations name the categories and require each state to include its
definition of each work activity in the annual report it must file each
year with HHS. Hours spent in some activities (referred to as
supplemental activities) generally cannot count toward the federal work
requirement unless hours are also spent in other countable activities
(referred to as core activities). Some activities have restrictions on
the amount of time that can be spent in them. The 12 categories and
their time restrictions are shown in table 1.
Table 1: 12 Categories of Federal Work Activities and Limitations on
Counting Time in Those Activities:
Activity: Core activities:
Activity: 1. Unsubsidized employment; Limitations on counting time (for
all families): None.
Activity: 2. Subsidized private sector employment; Limitations on
counting time (for all families): None.
Activity: 3. Subsidized public sector employment; Limitations on
counting time (for all families): None.
Activity: 4. Work experience;
Limitations on counting time (for all families): None.
Activity: 5. On-the-job training; Limitations on counting time (for all
families): None.
Activity: 6. Job search and job readiness assistance; Limitations on
counting time (for all families): 6-week time limit per client per
year, no more than 4 weeks consecutively.
Activity: 7. Community service programs; Limitations on counting time
(for all families): None.
Activity: 8. Caring for child of community service participant;
Limitations on counting time (for all families): None.
Activity: 9. Vocational education training; Limitations on counting
time (for all families): 12-month total time limit per client.
Activity: Supplemental activities:
Activity: 10. Job skills training directly related to employment;
Limitations on counting time (for all families): Counts only after
accumulating 20 hours in a core activity.
Activity: 11. Education directly related to work; Limitations on
counting time (for all families): Counts only after accumulating 20
hours in a core activity (except if under 20 years old).
Activity: 12. Satisfactory attendance at high school or equivalent;
Limitations on counting time (for all families): Counts only after
accumulating 20 hours in a core activity (except if under 20 years
old).
Source: GAO analysis of section 407 of PRWORA and HHS regulations.
Note: This table does not show all the provisions that apply to the 12
categories.
[End of table]
Single Audits:
The Single Audit Act, as amended,[Footnote 8] established the concept
of having one audit of an entity as a whole instead of multiple audits
of individual grants received by the entity.[Footnote 9] The act
requires state and local governments and nonprofit organizations that
expend $500,000 or more in federal funds during the year to undergo an
organizationwide audit.[Footnote 10] These audits focus on the entity's
internal controls and compliance with laws and regulations governing
federal awards and should be viewed as a tool that raises relevant or
pertinent questions rather than a document that answers all questions.
Office of Management and Budget (OMB) Circular A-133, Audits of States,
Local Governments, and Non-Profit Organizations, provides the federal
guidance for single audits. It contains a Compliance Supplement that
summarizes key information about federal programs and identifies audit
objectives and suggested procedures for auditors' use in determining
compliance with the requirements. The Compliance Supplement contains
information on TANF, along with over a hundred other federal programs.
The information on TANF includes some key line items, including those
for reporting hours of work activity, from the TANF data report that
states must submit to ACF.
Internal Controls:
Internal controls comprise the plans, methods, and procedures an
organization uses to meet its missions, goals, and objectives. Internal
controls are a series of actions and activities that occur throughout
an organization's operations and on an ongoing basis. They provide
reasonable assurance that an organization achieves its objectives of
(1) effective and efficient operations, (2) reliable financial
reporting, and (3) compliance with laws and regulations. An
organization's internal controls over collecting and reporting data
could include numerous processes and procedures, such as guidance that
defines the specific data to be collected and any documentation needed
to support that data and monitoring to ensure that the reported data
are complete and accurate.
Differences in How States Define Work Activities Result in Inconsistent
Measurement of Work Participation across States and over Time:
We found that differences in how states define the 12 categories of
federal work activities result in some states counting hours recipients
spend in activities that other states do not consider allowable
activities for meeting federal work participation requirements. Also,
some states have made changes in their definitions of some categories
of federal work activities, making what is measured by those states'
work participation rates inconsistent from year to year. Further, some
differences across states in their classification of adult recipients
can result in certain types of recipients being excluded from some
states' work participation rates but included in other states' rates.
Activities Are Defined Inconsistently across States:
Although PRWORA outlines 12 categories of work activities that can
count toward meeting federal work participation requirements, states
are able to define the specific activities that fall under each of the
categories. We found that differences in how states define the 12
categories of work result in some states counting hours spent in
certain activities toward meeting the work participation rate, while
other states do not count hours spent in those activities.
Although PRWORA outlined 12 categories of work activities that count
toward meeting work participation rates, PRWORA does not prevent states
from allowing their recipients to participate in other noncountable
activities, such as activities that help the recipients overcome
problems that prevent them from working. In our review of state TANF
documents, we identified several activities that were commonly
mentioned but that were treated differently by different states, such
as substance abuse treatment. One state may include the activity under
1 of the 12 categories of work, while other states may consider that
activity a state activity that does not count toward meeting the
federal work requirement.
Table 2 shows how many of the 10 reviewed states counted certain
activities that were commonly mentioned in state TANF documents toward
meeting federal work participation requirements. (See app. II for
states included in the table). States were counting these activities
toward meeting the work participation rate by defining one of the 12
categories of work as including the activities.
Table 2: The Number of 10 Reviewed States That Count Certain Activities
toward Meeting the Federal Work Participation Rate and the Categories
of Work in Which the States Counted the Activities:
Activity: Caring for a disabled household or family member; Number of
10 reviewed states that count the activity as federal work
participation: 5; Federal categories of work in which the reviewed
states counted the activity: Community Service.
Activity: Substance abuse treatment; Number of 10 reviewed states that
count the activity as federal work participation: 6; Federal categories
of work in which the reviewed states counted the activity: Job
Search/Readiness, Work Experience, Community Service.
Activity: Domestic violence counseling; Number of 10 reviewed states
that count the activity as federal work participation: 3; Federal
categories of work in which the reviewed states counted the activity:
Job Search/Readiness, Work Experience, Community Service.
Activity: Other mental health counseling; Number of 10 reviewed states
that count the activity as federal work participation: 5; Federal
categories of work in which the reviewed states counted the activity:
Job Search/Readiness, Work Experience, Community Service.
Activity: English as a second language; Number of 10 reviewed states
that count the activity as federal work participation: 7; Federal
categories of work in which the reviewed states counted the activity:
Job Skills Training, Secondary School or Education Directly Related to
Employment, Community Service, Vocational Education.
Source: GAO review of 10 states' TANF documents and interviews with the
states' TANF officials.
Note: An additional state counts substance abuse treatment, domestic
violence counseling, and other mental health counseling toward meeting
the federal work participation rate in limited circumstances.
[End of table]
Some states have a very broad definition for at least one federal
category of work that allows the states to include many diverse
activities under the category. For example, one state that defines
Community Service as "an activity approved by your case manager which
benefits you, your family, your community or your tribe" considered all
five of the activities shown in table 2 to fall under the Community
Service category.
A few states had activities listed in the definition of a federal work
activity that we did not see in other states' definitions, such as:
* bed rest, short-term hospitalizations, and personal care activities a
participant is engaged in as part of recovery from a medical problem
(Job Search/Job Readiness);
* physical rehabilitation, which could include massage, regulated
exercise, or supervised activity with the intent of promoting recovery
or rehabilitation (Job Search/Job Readiness);
* activities to promote a healthier life style that will eventually
assist the recipient in obtaining employment, such as personal
journaling, motivational reading, exercise at home, smoking cessation,
and weight loss promotion (Job Search/Job Readiness);
* participating in your child's Head Start or Early Head Start programs
by participating in home visits, parent meeting presentations, and
classroom volunteering (Community Service); and:
* helping a friend or relative with household tasks and errands
(Community Service).
Increasing the number of activities that it counts toward the federal
work participation rate should help a state increase its work
participation rate and avoid incurring penalties. Out of our 10
reviewed states, 2 states counted all five of the activities shown in
table 2 above, while 1 state did not count any. Such variation in the
number of activities that states count toward the federal work
participation rate suggests that the states are subject to different
standards for work participation. Because of the differences in states'
internal controls over their work participation data (discussed in the
next section of this report), the data cannot be relied upon for making
comparisons across states. Therefore, we did not analyze states' work
participation rates in relation to the number of activities they
counted toward work participation.
Changes in State Definitions Result in Inconsistent Measurement from
Year to Year:
Three of the 10 states we reviewed had made changes in their
definitions of work activities within the past 2 years that may have
affected their work participation rates and that could result in work
participation rates that are not comparable over time. Kansas had a
dramatic change in its work participation rate after changing some of
its definitions. This state had a waiver exempting it from the 6-week
limit for counting hours recipients spent in Job Search/Job Readiness
activities. For states with waivers, the effective work participation
rate is calculated based on the conditions of the waiver. However, ACF
also calculates a without-waiver rate for states with waivers. After
the state lost its waiver, it redefined some of its categories of work
by placing activities previously in the Job Search/Job Readiness
category (the category that had been covered by the waiver) into other
categories that do not have time restrictions, such as Community
Service. For this state, the 2003 with-waiver rate was significantly
higher than the without-waiver rate. If the without-waiver rate had
been the effective rate, the state would have been subject to penalty
for not meeting the required work participation rate. One month after
the waiver expired and the definitions were changed, the state's rate
without the waiver rose over 50 percentage points to reach the level of
the 2003 with-waiver rate.
Another state, Nevada, also moved some activities from Job Search/Job
Readiness to Work Experience to avoid the 6-week time limit on counting
hours spent in Job Search/Job Readiness. According to a state official,
the change was made because, as a result of the 6-week time limit,
field workers would sometimes make decisions that were not in the best
interest of the recipients and move recipients out of activities too
quickly. The state official believes that the change is likely to help
raise the state's work participation rate.
Georgia added an additional activity (caring for a disabled relative
who does not live with the recipient) to its Community Service category
and broadened the definition of job skills training to allow for
general training for a job, rather than just training for a specific
job. According to a state official, these changes have helped the state
increase its work participation rate.
Other Differences in Classifications of Adult Recipients Result in
Inconsistencies across States:
Some differences among states in their classification of recipients
affect whether or not recipients are included in the work participation
rate calculation. We found the following different approaches that
remove recipients from the work participation rate calculation.
* Creating separate state programs for two-parent families.[Footnote
11] By serving two-parent families through separate state programs,
states remove those families from the calculation of work participation
rates.[Footnote 12] Four of the 10 states in our review (California,
Georgia, Maryland, and Nevada) had created separate state programs for
two-parent families. Officials from Georgia, Maryland, and Nevada said
that they created the programs because they wanted to avoid having to
meet the higher two-parent family work requirement.[Footnote 13]
Officials from the states we reviewed with separate state programs for
two-parent families said that although the states do not have to meet a
federal work participation requirement for their two-parent families,
they still require the adult recipients in the two-parent families to
comply with the states' work requirements.
* Moving recipients with significant barriers into a separate state
program. Nevada placed recipients who are less likely to meet the
federal work participation requirements in a separate state program,
thus removing them from the work participation rate calculation. These
include recipients (1) with pending applications for Supplemental
Security Income, (2) with medical difficulties confirmed by a
physician, (3) in the third trimester of pregnancy, and (4) caring for
a disabled family member. According to a state official, these
recipients are still required to participate in work activities to the
extent that they are able.
* Reclassifying cases as child-only. California removes adults from
TANF cases when they are sanctioned, thus changing the cases from adult-
headed cases to child-only cases.[Footnote 14] Because child-only cases
are not included in state work participation calculations, the
reclassification allows the state to avoid counting noncomplying adults
in the calculation, which in turn is likely to result in a higher work
participation rate. According to a state official, the state's practice
of reclassifying cases this way preceded the implementation of TANF and
therefore was not intended to influence the state's TANF work
participation rate.
Some States Do Not Have Internal Controls Needed for Reporting Data in
Accordance with HHS Guidance, while Other States Do:
Some of the states we reviewed did not have internal controls to help
ensure that reported hours of participation in work activities are in
accordance with HHS guidance. Other states have implemented systematic
practices to help ensure that reported hours are in accordance with HHS
guidance. Officials in some states cited challenges to obtaining
support for hours of participation in unsubsidized employment.
Some States Lack Internal Controls to Help Ensure Actual Hours of
Participation Are Reported:
Some of the states we reviewed did not have internal controls to help
ensure that reported hours of participation in work activities are in
accordance with HHS guidance. The HHS guidance (as discussed more fully
later in this report) requires that states report hours recipients
actually participated in work activities rather than hours that the
recipients were scheduled to participate. Internal control weaknesses
among the states we reviewed include the following:
* Guidance and/or standard processes allow reporting of scheduled
hours. In some states, we found that the hours recorded to show how
recipients plan to comply with state work requirements (scheduled
hours) were reported to ACF as hours actually worked. Reporting hours
scheduled instead of hours worked does not take into account unexpected
events or noncompliance on the part of the recipient that would result
in scheduled hours being different than the hours actually worked.
Allowing scheduled hours to be reported was most common for
unsubsidized employment, but in a few states, we found guidance
allowing scheduled hours for other work activities, such as vocational
education. In one state, guidance instructs that a set number of hours
be recorded for certain activities, such as 30 hours per week for
parents involved in their children's Head Start program. However, the
guidance does not indicate that the number of hours recorded should be
verified to ensure that they were actual hours of participation.
* Lack of guidance on the type of documentation needed to support
reported hours of work activities. Without guidance, there is no
assurance that the local staff collecting the data know what type of
documentation is adequate to support hours reported or whether any
documentation is required. The type of support needed would depend on
the activity but could include pay stubs and time and attendance
reports. Without guidance, staff at different locations are more likely
to use different standards for what support is needed.
* Guidance allows for reporting hours missed for good cause. Some
states have guidance specifying that when recipients are absent from a
scheduled activity and the case worker determines that there is a good
cause for the absence, the missed hours can be reported as worked. This
results in hours that were not worked being reported to ACF as worked.
* Insufficient monitoring to verify that hours were reported correctly.
Some states do not have a monitoring process in place to perform timely
reviews to verify that hours were reported correctly.[Footnote 15]
Without sufficient monitoring, states cannot be assured that local
staff are reporting hours that are supportable and complete.
Table 3 shows the number of states with the internal control weaknesses
described above for the states in our review. (See app. III for states
included in the table).
Table 3: Number of Reviewed States Lacking Internal Controls to Help
Ensure Hours of Participation Are Reported in Accordance with HHS
Guidance:
Internal control weakness: Guidance and/or standard processes allow
reporting of scheduled hours; Number of states (out of 9 reviewed) with
the internal control weakness: 3.
Internal control weakness: Lack of guidance on the type of
documentation needed to support reported hours of work activities;
Number of states (out of 9 reviewed) with the internal control
weakness: 4.
Internal control weakness: Guidance allows for reporting hours missed
for good cause; Number of states (out of 9 reviewed) with the internal
control weakness: 2.
Internal control weakness: Insufficient monitoring to verify that hours
were reported correctly; Number of states (out of 9 reviewed) with the
internal control weakness: 3.
Source: GAO review of 9 states' TANF documents and interviews with
their TANF officials.
Notes: (1) The table only covers 9 states because we were unable to
assess the internal controls of one of the 10 states we reviewed. (2)
For states where the internal control activities were determined at the
local level, we identified the state as having an internal control
weakness if the state did not ensure that the local areas were
implementing such internal controls.
[End of table]
Six of the states in our review have at least one of the internal
control weaknesses shown in table 3, and 3 of these states have at
least two internal control weaknesses. Two states that did not have any
of the internal control weaknesses have issued appropriate guidance and
begun monitoring as part of corrective action plans developed in
response to state audit findings on data problems. The states we
reviewed may have internal control weaknesses over the collection and
reporting of work participation data that our review was not designed
to assess. For example, a state may have issued appropriate guidance
and established a monitoring process; however, the state's staff may
not follow the guidance or conduct monitoring according to the required
process.
Some States Have Systematic Approaches for Verifying Reported Data:
While some of the states we reviewed lacked internal controls, other
states have implemented systematic practices to help ensure that
reported data are in accordance with HHS guidance.
* Documentation requirements. Some states we reviewed had guidance
outlining the specific documentation needed to verify actual hours for
each work activity and specified when the documentation must be
obtained and the hours recorded in the state's database.
* Monthly audits. Officials in some states we reviewed told us they
conduct monthly audits of all cases sampled for reporting to ACF to
verify that hours reported were actually worked. If there is not
adequate support showing that hours reported were actually worked, the
data are not reported to ACF, according to state officials.
Unsubsidized Employment Has Been Especially Difficult to Track:
State officials cited challenges to obtaining support for hours of
participation in unsubsidized employment. For some states, the standard
process for obtaining hours of unsubsidized employment occurs every 6
months when local staff reverify a recipient's income and benefit
eligibility. Income is typically verified with a recent pay stub, which
is then used to project the hours the recipient will be working for the
next 6 months. Some officials told us that trying to obtain
documentation for actual hours of unsubsidized employment from
recipients or employers monthly would be onerous for case workers and
recipients. Officials said they feared that contacting employers
frequently to verify a recipient's employment could jeopardize the
recipient's job. In states requiring monthly documentation, such as pay
stubs, for hours of work reported to HHS, state officials told us they
were likely underreporting hours because of the difficulty local staff
face in obtaining the required documentation.
A new effort on the part of ACF may provide states with additional
options for obtaining information on hours recipients spend in
unsubsidized employment. ACF recently began an initiative using the
National Directory of New Hires (NDNH)[Footnote 16] to help states
identify whether or not recipients are eligible for TANF benefits. If a
state chooses to participate, HHS will conduct data matches comparing
NDNH employee data against the state's list of TANF recipients. If the
data matches identify recipients who are working and are still eligible
for TANF, the data may provide states with a starting point for
obtaining more complete work participation data, according to an ACF
official. Because the NDNH does not contain hours worked, states would
need to contact employers or recipients to obtain information on the
actual hours the recipient worked, according to an ACF official.
HHS's Oversight and Guidance on Appropriately Defining Work Activities
and Reporting Hours of Work Participation Have Been Limited:
HHS has provided minimal oversight of how states define work
activities. Further, HHS has limited guidance for states on reporting
the appropriate hours of work activities. HHS does not have a
sufficient mechanism to identify data not in accordance with ACF
guidance.
HHS Has Provided Minimal Oversight of States' Definitions of Work
Activities:
Under PRWORA, HHS has authority to regulate states' definitions of work
activities. However, HHS has chosen not to issue regulations for this
purpose in order to promote the flexibility PRWORA provided states and
in response to calls from states for as much flexibility as possible in
designing their TANF programs, according to HHS officials. The current
TANF regulations only repeat the 12 categories of work activities that
are included in PRWORA and do not further specify activities that can
and cannot be included under the 12 categories. Further, the current
TANF regulations do not state that HHS will review states' definitions
of work activities to determine if the definitions are appropriate.
Accordingly, HHS officials said they are unable to direct states to
change their definitions of work activities when they believe the
states' definitions are inappropriate, as has occurred in the past.
HHS Has Provided Limited Guidance to States on the Appropriate Hours to
Report:
Although HHS has provided states with general guidance on reporting
actual hours of work participation, the guidance lacks specific
criteria for determining the appropriate hours to report. The
requirement for reporting actual hours of work participation is not
specified in federal regulations but is instead described in other
documents. The guidance on the type of hours are the following:
HHS regulations[Footnote 17]
* Quarterly reports containing work participation data must be
"complete and accurate."
HHS responses to comments to proposed regulations[Footnote 18]
* Hours for which the recipient was paid may be reported as hours
worked, such as paid holidays.
HHS Web site[Footnote 19]
* States must report actual hours of participation for each work
activity.
* Reporting required (or scheduled) hours of participation is
inconsistent with the "complete and accurate" standard and is not
acceptable.
Detailed reporting instructions for TANF data report (reporting
instructions)[Footnote 20]
* States are to report actual hours of participation.
* It is not acceptable to report scheduled hours of participation.
* States should validate actual participation in each work activity.
While HHS guidance calls for states to report actual hours, ACF
officials acknowledged it may be difficult or impossible to obtain
information on actual hours for some activities. For example, the ACF
officials cited problems states have in obtaining hours of actual
participation for recipients enrolled in vocational education courses,
community colleges, and universities for which attendance is not taken.
HHS Does Not Have a Sufficient Mechanism to Identify Data Not in
Accordance with ACF Guidance:
ACF uses two mechanisms to identify problems with work participation
data submitted by states--computer edit checks and reviews of single
audit findings. However, neither mechanism provides ACF with reasonable
assurance that data reported are in accordance with ACF guidance.
Computer edit checks. ACF performs edit checks of the data submitted
quarterly by states. The edit checks identify outliers, such as if a
recipient is reported to have participated in 80 hours of work
activities for 1 week. The edit checks also identify inconsistencies
between data elements, such as if a recipient is reported as having
earnings but is also reported as having zero hours of work. ACF
notifies states of any problems identified by the edit checks so that
states can correct and resubmit the data. The edit checks can help
improve the data; however, they do not address the issue of verifying
whether hours reported are actual hours of participation.
State single audits. According to ACF officials, HHS's primary vehicle
for identifying problems with the states' data is states' single audit
reports. Findings from the state single audits go through a review
process at HHS to determine whether penalties are warranted. HHS has
used findings from the single audit to take action against a state for
reporting poor quality work participation data.[Footnote 21] However,
ACF officials acknowledged that the work participation data reported by
states may have problems that the single audits may not reveal. Our
interviews with auditors in the 10 states we reviewed indicate that the
level of attention given to work participation data varies greatly
among the states.
* State auditors from 5 states (California, Georgia, Maryland, Nevada,
and Ohio) told us that their most recent single audits covering the
TANF program[Footnote 22] did not review the data states report to HHS
on hours of participation in work activities.[Footnote 23]
* Out of the 5 states in which state auditors reported that the most
recent single audits did test hours of work participation:
* Three states (Kansas, Washington, and Wisconsin) reported that the
audits did not look for support of actual hours but instead compared
hours shown in the state's welfare database with the hours reported to
HHS for a sample of cases. State auditors for the 3 states did not
report any findings on work participation data from these reviews.
* Two states (New York and Pennsylvania) looked for supporting
documentation to verify that hours reported to ACF were hours of actual
participation for a sample of cases. In New York, the audit had no
finding regarding work participation hours.[Footnote 24] The audit for
Pennsylvania found that some reported hours had no supporting
documentation to verify that they were actually worked. According to
state officials, Pennsylvania has implemented corrective actions in
response to the single audit findings.
Our review of the 10 states' internal controls identified weaknesses
both in states where state auditors told us that the most recent single
audit did not test the data reported to HHS on hours of participation
in work activities and in states that did. ACF officials acknowledged
that because of the broad nature of the single audits, the quality and
focus of the audits vary from state to state. The single audit,
covering hundreds of federal programs, is designed as a tool that
raises relevant questions about states' internal controls and
compliance with laws and regulations governing federal awards but is
not intended to answer all questions. State auditors responsible for
conducting the single audits are provided with federal guidance issued
by OMB--known as the Compliance Supplement. Currently the Compliance
Supplement contains reference to work participation data only as a key
line item for auditors to look at in the TANF data report. According to
ACF officials, the fiscal year 2005 Compliance Supplement for the
single audit will contain more guidance to help auditors identify
whether work participation data are reported in accordance with HHS
guidance. The addition to the Compliance Supplement will suggest that
state auditors test a sample of cases to determine the completeness and
accuracy of the data, including the proper documentation, used in
calculating the work participation rate.
Conclusions:
By listing 12 categories of permissible work activities, Congress
placed limits on the type of activities that states could count toward
meeting federal work participation requirements. HHS regulations only
restate the 12 categories of work activities and do not further specify
the types of activities that can and cannot count toward meeting the
federal work requirements, nor do they provide for HHS's oversight of
states' definitions of the 12 categories. HHS has taken the position
that with the current limited regulations, it will not place
restrictions on the activities states can count toward meeting TANF
work requirements. As a result, states have been able to include any
activity in their definitions of the 12 categories of work. Several
states have broadly defined 1 or more of the categories to include
activities, such as substance abuse treatment, that other states
provide but do not consider countable toward meeting the federal work
participation requirement. Another discrepancy among states occurs with
the internal controls over the data they report to HHS. For example,
some states only report hours that have been verified as having been
actually worked, while others report hours without verification.
Because of the differences among states in the activities that they
count in calculating the work participation rate and in the internal
controls over the data used in the calculation, states are being
measured by different standards, and the work participation rates
cannot be used to compare the performance of states. Further, a high
work participation rate does not necessarily indicate more engagement
of TANF recipients in work activities than a lower rate.
The current caseload reduction credit has greatly reduced the required
level of work participation for most states. However, if TANF
reauthorization results in lowering the caseload reduction credit and
raising the work participation requirements, more states could be
penalized, and states with strict definitions and effective internal
controls may be the most susceptible to penalties. If the TANF work
participation rate is to be an effective and equitable measure for
assessing states' performance and penalizing states, HHS needs to give
more oversight to states' definitions of federal work activities and
internal controls over the data to help make the measure more
consistent across states. We acknowledge that efforts to obtain more
valid, accurate, and consistent information for this performance
measure may have unintended consequences. For example, it may motivate
states to use separate state programs or make other choices about the
design of their TANF programs. However, a measure that is used to
assess penalties needs to be clear and consistent for all those
potentially subject to penalty; otherwise, the measure can result in
misleading information and inequitable penalty assessments.
Recommendations for Executive Action:
HHS should issue regulations to:
* specify the types of activities that can and cannot be included under
the 12 categories of work activities,
* have HHS oversee states' definitions of activities under the 12
categories, and:
* set forth criteria for counting actual hours of activity and whether
there are circumstances under which scheduled hours may be counted.
We also recommend that HHS develop and implement a plan for working
with states to improve internal controls over work participation data.
This plan could make use of existing resources and include steps such
as:
* working through its regional offices to identify cost-effective
internal controls being used by states,
* using regional offices and existing sponsored conferences to share
information with states on these internal controls and to emphasize the
importance of internal controls, and:
* obtaining information from states about their experiences using the
National Directory of New Hires to determine if it has potential for
helping states collect more complete work participation data and if
there are any useful practices to be shared with other states.
Agency Comments and Our Evaluation:
HHS provided written comments on a draft of this report; these comments
appear in appendix V. HHS said that the report provides it with new and
useful information. HHS said it would consider making the recommended
revisions in its regulations after TANF reauthorization and is
exploring options for implementing the recommendation on internal
controls. HHS also provided technical comments that we incorporated as
appropriate.
Concerning our recommendation that HHS issue regulations to provide
oversight of states' definition and more guidance on counting hours of
work activities, HHS said that it will consider this recommendation
when it develops the proposed rule after Congress enacts legislation to
reauthorize the TANF program. We agree that addressing this
recommendation during rule making after TANF reauthorization is
appropriate, if TANF is reauthorized in the near future. However, TANF
reauthorization has been delayed for 3 years and if it is delayed for
much longer, HHS should take action to revise TANF regulations without
waiting for reauthorization. Concerning our recommendation that HHS
develop and implement a plan for working with states to improve
internal controls over the work participation data, HHS said it
recognized that more can be done to ensure increased consistency in the
accuracy of the work participation data. HHS also stated that ACF is
exploring options to increase oversight and provide technical
assistance to states using its currently limited resources. Further,
HHS noted that federal staff for TANF had been reduced by 75 percent
several years ago. We added a statement about this staff reduction to
the background section of the report.
HHS expressed concern that the draft report did not sufficiently
recognize the flexibility that Congress intended for the TANF program,
and it stated that Congress did not intend that there be a consistent
measure of work participation across states or that HHS make state-by-
state comparisons for penalty purposes. We believe that the report does
recognize the flexibility Congress provided to states. Also, we believe
that the fact that Congress gave states the flexibility to design their
TANF programs does not indicate that Congress did not want a meaningful
measure to determine if states are meeting TANF requirements. While
states have flexibility in determining what policies they will use to
achieve TANF goals and requirements, the measure used to assess their
performance should be defined the same way from state to state;
otherwise, the rates produced by the measure cannot provide meaningful
and understandable information for national policy makers and for
assessing financial penalties. Further, although the use of waivers and
separate state programs contributes to differences in which families
are included in the work participation rate, HHS has made efforts,
through its annual reporting, to ensure transparency about the rules
governing these mechanisms and which states are using them. The lack of
oversight of states' definitions of categories of work activities
results in inconsistencies in performance measurement, as discussed in
this report, that are not transparent.
HHS noted some imprecision in the draft report's description of the
work participation rate calculation. In response, we made revisions to
the report. HHS also took issue with our discussion of how a state's
work participation rate changed after its waiver expired. We continue
to believe that this example of how a state's rate changed over 50
percentage points 1 month after the waiver expired is a useful
illustration of how changes in definitions can affect work
participation rates.
As agreed with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
after its issue date. At that time, we will send copies of this report
to the Secretary of the Department of Health and Human Services,
relevant congressional committees, and others who are interested.
Copies will be made available to others upon request, and this report
will also be available on GAO's Web site at http://www.gao.gov.
If you or your staff have any questions about this report, please
contact me on (415) 904-2272. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last
page of this report. Additional GAO contacts and acknowledgments are
listed in appendix VI.
Sincerely,
Signed by:
David Bellis, Director:
Education, Workforce, and Income Security:
[End of section]
Appendix I: Elements of the Work Participation Requirement and How the
Work Participation Rate Is Calculated:
The Temporary Assistance for Needy Families (TANF) work participation
requirement is composed of (1) a requirement for a minimum number of
hours recipients must participate in order to be counted as engaged in
work activities and (2) a requirement for the percentage of TANF
families with an adult (or minor head of household) a state must have
engaged in work activities. The Department of Health and Human
Services' Administration for Children and Families (ACF) uses a formula
specified in the Personal Responsibility and Work Opportunity
Reconciliation Act for calculating whether states are meeting the work
participation requirement.
The Minimum Number of Hours TANF Recipients Must Participate:
The minimum number of hours TANF recipients must participate, on
average, per week to be counted as engaged in work is shown in table 4.
Table 4: Number of Hours Different Types of Recipients Must Participate
in Allowed Work Activities to Count as Working in the TANF All-Family
Work Participation Rate:
Type of recipient: Single parent with a child under 6 years old;
Required number of hours on average per week (or activity): 20.
Type of recipient: Other adult recipients; Required number of hours on
average per week (or activity): 30.
Type of recipient: Single parent under 20 years old; Required number of
hours on average per week (or activity): Satisfactory school attendance
or equivalent.
Source: GAO analysis of TANF regulations.
Note: Adults in two-parent families have different requirements for the
number of hours of activity.
[End of table]
Base Percentage of a State's TANF Families Who Must Be Engaged in Work
Activities:
Different base percentages were established for all families and for
two-parent families. The required percentages rose over time until they
reached their current levels shown in table 5.
Table 5: Base Percentage of TANF Families That Must Be Engaged in Work
for the All-Family and the Two-Parent Family Rates:
Type of participation rate: All-family (single and two-parent
combined); Current required rate: 50%.
Type of participation rate: Two-parent families; Current required rate:
90%.
Source: GAO analysis of TANF regulations.
Note: This base percentage is adjusted for each state using the
caseload reduction credit.
[End of table]
Caseload Reduction Credit That Reduces the Base Percentage:
For each percentage point that a state's welfare caseload declined from
its 1995 level, the caseload reduction credit reduces the base
percentage of TANF families who must be engaged in work in the state.
For example, if a state's welfare caseload declined 40 percent since
1995, then the all-family work participation rate that it must meet is
10 percent and the two-parent family work participation rate that it
must meet is 50 percent. Because of significant declines in welfare
caseloads that have occurred in most states since 1995, 33 of the 50
states were required to meet an all-family rate of 10 percent or less
in fiscal year 2003.
Calculation of Each State's Work Participation Rate:
Each quarter, states are required to report to ACF monthly data on
their TANF cases, including the number of hours each adult recipient
spent in countable work activities. States have the option of reporting
to ACF on all their TANF cases (the universe) or on a scientifically
drawn sample of TANF cases.[Footnote 25] Using the data reported by
states, ACF calculates an annual work participation rate for each
state. A state's annual work participation rate is based on the state's
average monthly rate for the year. The formula for the all-family rate
is shown in figure 1.
Figure 1: Formula for Calculating the All-Family Work Participation
Rate:
[See PDF for image]
Note: For the purposes of this formula, the term "adult" refers to TANF
recipients age 20 or over or recipients under age 20 who are head of a
household receiving TANF.
[End of figure]
Child-only TANF cases are not included in the calculation. States have
the option of disregarding from the calculation of the all-family work
participation rate families with a single custodial parent and a child
under age one. Other families disregarded in the calculation of the all
family rate include:
≤ families that are part of an ongoing research evaluation approved
under Section 1115 of the Social Security Act;
≤ families that are disregarded based on an inconsistency under an
approved welfare reform waiver that exempts the family; and:
≤ families participating in a tribal family assistance plan or a Tribal
work program (unless the state chooses to include the families in the
calculation).
The two-parent family rate is calculated the same way as the all-family
rate, except that the calculation only includes two-parent families.
Two-parent families with a disabled parent are not used in calculating
the two-parent rate.
[End of section]
Appendix II: States That Count Certain Activities toward Meeting the
Federal Work Participation Rate:
Table 6: States Covered by the Review That Count Certain Activities
toward Meeting the Federal Work Participation Rate:
Activity: Caring for a disabled household or family member; Reviewed
states that count the activity as federal work participation: Georgia,
Maryland, New York, Washington, Wisconsin.
Activity: Substance abuse treatment; Reviewed states that count the
activity as federal work participation: Kansas, Maryland, Nevada, New
York, Washington, Wisconsin.
Activity: Domestic violence counseling; Reviewed states that count the
activity as federal work participation: Nevada, Washington, Wisconsin.
Activity: Other mental health counseling; Reviewed states that count
the activity as federal work participation: Kansas, Nevada, New York,
Washington, Wisconsin.
Activity: English as a second language; Reviewed states that count the
activity as federal work participation: Kansas, Nevada, New York, Ohio,
Pennsylvania, Washington, Wisconsin.
Source: GAO review of 10 states' TANF documents and interviews with the
states' TANF officials.
Note: In the limited circumstance that counseling is related to
employment and is given to a recipient along with employment services
by the same service provider, Ohio counts hours spent in substance
abuse treatment, domestic violence counseling, and other mental health
counseling toward meeting the federal work participation rate,
according to an Ohio official.
[End of table]
[End of section]
Appendix III: States Identified as Lacking Certain Internal Controls:
Table 7: States Covered by the Review That Lacked Internal Controls to
Help Ensure Hours of Participation Are Reported in Accordance with HHS
Guidance:
Internal control weakness: Guidance and/or standard processes allow
reporting of scheduled hours; States (out of 9 reviewed) with the
internal control weakness: Georgia, Kansas, Ohio.
Internal control weakness: Lack of guidance on the type of
documentation needed to support reported hours of work activities;
States (out of 9 reviewed) with the internal control weakness:
California, Kansas, New York, Wisconsin.
Internal control weakness: Guidance allows for reporting hours missed
for good cause; States (out of 9 reviewed) with the internal control
weakness: Wisconsin, New York.
Internal control weakness: Insufficient monitoring to verify that hours
were reported correctly; States (out of 9 reviewed) with the internal
control weakness: Kansas, New York, Wisconsin.
Source: GAO review of 9 states' TANF documents and interviews with
their TANF officials.
Notes: (1) Washington is not included in this table because we were
unable to assess its internal controls. (2) For states where the
internal control activities were determined at the local level, we
identified the state as having an internal control weakness if the
state did not ensure that the local areas were implementing such
internal controls. (3) We considered state monitoring of local offices
to be insufficient if it occurred less than yearly and did not verify
that hours in work activities were reported correctly.
[End of table]
[End of section]
Appendix IV: Fiscal Year 2003 Work Participation Rates Calculated by
HHS Based on Data Provided by States:
As discussed in this report, our review covering 10 states found that
there were differences among states in the activities counted in the
rates and, in some cases, weaknesses in internal controls over the data
used to calculate the rates. Therefore, these rates may not reliably
reflect work participation rates and should not be used to make
comparisons between states.
Table 8: Fiscal Year 2003 Work Participation Rates Calculated by HHS
Based on Data Provided by States:
State: Alabama;
All-families rate: 37;
Two-parent families rate[A]: N/A.
State: Alaska;
All-families rate: 41;
Two-parent families rate[A]: 45.
State: Arizona;
All-families rate: 13;
Two-parent families rate[A]: 55.
State: Arkansas;
All-families rate: 22;
Two-parent families rate[A]: 32.
State: California;
All-families rate: 24;
Two-parent families rate[A]: N/A.
State: Colorado;
All-families rate: 33;
Two-parent families rate[A]: 40.
State: Connecticut;
All-families rate: 31;
Two-parent families rate[A]: N/A.
State: Delaware;
All-families rate: 18;
Two-parent families rate[A]: N/A.
State: Florida;
All-families rate: 33;
Two-parent families rate[A]: N/A.
State: Georgia;
All-families rate: 11;
Two-parent families rate[A]: N/A.
State: Hawaii;
All-families rate: 66;
Two-parent families rate[A]: N/A.
State: Idaho;
All-families rate: 44;
Two-parent families rate[A]: 42.
State: Illinois;
All-families rate: 58;
Two-parent families rate[A]: N/A.
State: Indiana;
All-families rate: 40;
Two-parent families rate[A]: N/A.
State: Iowa;
All-families rate: 45;
Two-parent families rate[A]: 39.
State: Kansas;
All-families rate: 88;
Two-parent families rate[A]: 87.
State: Kentucky;
All-families rate: 33;
Two-parent families rate[A]: 46.
State: Louisiana;
All-families rate: 35;
Two-parent families rate[A]: 39.
State: Maine;
All-families rate: 28;
Two-parent families rate[A]: 29.
State: Maryland;
All-families rate: 9;
Two-parent families rate[A]: N/A.
State: Massachusetts;
All-families rate: 61;
Two-parent families rate[A]: 74.
State: Michigan;
All-families rate: 25;
Two-parent families rate[A]: 36.
State: Minnesota;
All-families rate: 25;
Two-parent families rate[A]: N/A.
State: Mississippi;
All-families rate: 17;
Two-parent families rate[A]: N/A.
State: Missouri;
All-families rate: 28;
Two-parent families rate[A]: N/A.
State: Montana;
All-families rate: 86;
Two-parent families rate[A]: 96.
State: Nebraska;
All-families rate: 33;
Two-parent families rate[A]: N/A.
State: Nevada;
All-families rate: 22;
Two-parent families rate[A]: N/A.
State: New Hampshire;
All-families rate: 28;
Two-parent families rate[A]: N/A.
State: New Jersey;
All-families rate: 35;
Two-parent families rate[A]: N/A.
State: New Mexico;
All-families rate: 42;
Two-parent families rate[A]: 52.
State: New York;
All-families rate: 37;
Two-parent families rate[A]: 52.
State: North Carolina;
All-families rate: 25;
Two-parent families rate[A]: 49.
State: North Dakota;
All-families rate: 27;
Two-parent families rate[A]: N/A.
State: Ohio;
All-families rate: 62;
Two-parent families rate[A]: 68.
State: Oklahoma;
All-families rate: 29;
Two-parent families rate[A]: 51.
State: Oregon;
All-families rate: 60;
Two-parent families rate[A]: 53.
State: Pennsylvania;
All-families rate: 10;
Two-parent families rate[A]: 9.
State: Rhode Island;
All-families rate: 24;
Two-parent families rate[A]: 95.
State: South Carolina;
All-families rate: 54;
Two-parent families rate[A]: 51.
State: South Dakota;
All-families rate: 46;
Two-parent families rate[A]: N/A.
State: Tennessee;
All-families rate: 43;
Two-parent families rate[A]: N/A.
State: Texas;
All-families rate: 28;
Two-parent families rate[A]: N/A.
State: Utah;
All-families rate: 28;
Two-parent families rate[A]: N/A.
State: Vermont;
All-families rate: 24;
Two-parent families rate[A]: 38.
State: Virginia;
All-families rate: 45;
Two-parent families rate[A]: N/A.
State: Washington;
All-families rate: 46;
Two-parent families rate[A]: 44.
State: West Virginia;
All-families rate: 14;
Two-parent families rate[A]: 25.
State: Wisconsin;
All-families rate: 67;
Two-parent families rate[A]: 40.
State: Wyoming;
All-families rate: 83;
Two-parent families rate[A]: 92.
Source: Rates calculated by HHS based on data provided by states.
[A] Some states do not have two-parent families in their TANF programs.
Thus, the two-parent families rate is not applicable for some states,
as indicated by N/A.
[End of table]
[End of section]
Appendix V: Comments from the Department of Health and Human Services:
DEPARTMENT OF HEALTH & HUMAN SERVICES:
Office of Inspector General:
Washington, D.C. 20201:
AUG 2 2005:
Mr. David D. Bellis:
Director, Education, Workforce, and Income: Security Issues:
U.S. Government Accountability Office: Washington, DC 20548:
Dear Mr. Bellis:
Enclosed are the Department's comments on the U.S. Government
Accountability Office's (GAO's) draft report entitled, "WELFARE REFORM:
HHS Should Exercise Oversight to Help Ensure TANF Work Participation Is
Measured Consistently across States" (GAO-05-821). These comments
represent the tentative position of the Department and are subject to
reevaluation when the final version of this report is received.
The Department provided several technical comments directly to your
staff.
The Department appreciates the opportunity to comment on this draft
report before its publication.
Sincerely,
Signed by:
Daniel R. Levinson:
Inspector General:
Enclosure:
The Office of Inspector General (OIG) is transmitting the Department's
response to this draft report in our capacity as the Department's
designated focal point and coordinator for U.S. Government
Accountability Office reports. OIG has not conducted an independent
assessment of these comments and therefore expresses no opinion on
them.
COMMENTS OF THE U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES ON THE
U.S. GOVERNMENT ACCOUNTABILITY OFFICE'S DRAFT REPORT ENTITLED, "WELFARE
REFORM: HHS SHOULD EXERCISE OVERSIGHT TO HELP ENSURE TANF WORK
PARTICIPATION IS MEASURED CONSISTENTLY ACROSS STATES" (GAO-05-821):
General Comments:
The U.S. Department of Health and Human Services (HHS) appreciates the
opportunity to comment on the U.S. Government Accountability Office's
(GAO) draft report concerning how States define and report on work
participation activities used in the calculation of the work
participation rates and the scope of HHS's oversight role. Based on the
survey of 10 States and discussions with HHS staff, the report provides
information on the variation in States' definitions of work activities
and the extent of internal controls over the quality and accuracy of
the work participation data reported to HHS, Administration for
Children and Families (ACF). The report provides ACF with new and
useful information.
The report identifies inconsistencies in the way States surveyed define
individual activities under the 12 statutory categories of work
activities, as well as the variability in the scope of States' internal
controls to ensure complete and accurate work participation data. GAO
concludes that the work participation rates are neither comparable
between States nor over time within a State. GAO is critical of HHS for
failing to regulate the definition of work activities or to provide
adequate direction and oversight in this area.
We do not believe that GAO sufficiently recognizes the statutory
context of the Personal Responsibility and Work Opportunity
Reconciliation Act of 1996 (PRWORA). Congress, in enacting PRWORA,
explicitly specified that the purpose of the statute was to increase
the flexibility of States to implement a Temporary Assistance for Needy
Families (TANF) program focused on work and self-sufficiency. While the
statute provided ACF the authority to regulate the definition of work
activities, we explored this approach during our proposed and final
rule-making process, but concluded that such an approach would be
inconsistent with both the flexibility the statute provided States in
other areas of the work participation requirements and the overall
design of the program to foster creativity and innovation in the
delivery of services at the local level.
Congress clearly did not intend that there be a consistent measure of
work participation across States or that we make State-by-State
comparisons for penalty purposes. Congress permitted 19 States to
continue their Section 1115 (of the Social Security Act) Welfare Reform
waivers. With respect to the work participation rates, each of the 19
States had different waiver provisions which allowed them to count
different activities toward meeting the work requirement. Some States
were permitted to ignore limits on job search and vocational education
and/or the 20-hour requirement for core activities. Other States were
able to set a lower individual standard for required hours of
participation in work activities (e.g., PRWORA requires 30 hours per
week for a single parent with a child six years of age or older, of
which 20 hours per week must come from the core activities) to be
counted as engaged in work and/or to exclude families from the work
participation calculation that, absent the waiver, would not be
excluded. In addition to the waivers, Congress gave States substantial
latitude in designing programs and policies, which affect the
population being served by the TANF and Separate State Program-
Maintenance of Effort programs in each State. This included the
flexibility not to offer or include all 12 of the work activities that
can be counted in the work participation rate. In addition, other State
policies can have differential effects on participation rates. For
example, States with high benefits and generous earning disregards are
more likely to have high rates of unsubsidized employment, thereby
reducing the number of work activity slots that might have to be
created to serve other TANF families. These built-in differences make
it extremely difficult to make State-by-State comparisons. Congress
intended that each State's work participation rate be compared to the
standard Congress established given the State's flexibility to run its
own program.
GAO Recommendation:
HHS should revise its regulations to:
* specify the types of activities that can and cannot be included under
the 12 categories of work activities,
* have HHS oversee States' definitions of activities under the 12
categories, and:
* set forth criteria on counting actual hours of activities and whether
there are circumstances under which scheduled hours may be counted.
HHS Comments:
Because Congress is currently considering significant changes to the
work participation requirements as part of TANF reauthorization, we do
not think it is appropriate to begin a rule-making process at this
time. In fact, adopting GAO's recommendations prior to reauthorization
could create unnecessary disruptions in State programs. If ACF were to
specify some activities narrowly, some States might drop certain
program activities, only to have those activities allowed again under
one of the various reauthorization proposals that give States
considerable flexibility in defining work activities. At the very
least, the report should mention that reauthorization is a
consideration in the timing of revising regulations. However, we will
consider GAO recommendations when we develop the proposed rule after
Congress enacts legislation to reauthorize the TANF program.
GAO Recommendation:
We also recommend that HHS develop and implement a plan for working
with States to improve internal controls over the work participation
data. This plan could make use of existing resources and include steps
such as:
* working through its regional offices to identify cost-effective
internal controls being used by States;
* using regional offices and existing sponsored conferences to share
information with States on these internal controls and to emphasize the
importance of internal controls; and:
* obtaining information from States about their experiences using the
National Directory of New Hires to determine if it has potential for
helping States collect more complete work participation data and if
there are any useful practices to he shared with other States.
HHS Comments:
We appreciate the information GAO collected on the internal controls
from the surveyed States. We also recognize that more can be done to
ensure increased consistency in the accuracy of these data. ACF has
relied primarily on results from the Single State Audit for providing
oversight in this area. As GAO notes in the report, ACF has expanded
the work participation rate review specifications for completeness and
accuracy in the Fiscal Year (FY) 2005 Compliance Supplement. GAO
suggests that recommended increased oversight and technical assistance
to States by the Department can be done within existing resources. ACF
is currently exploring options in this area. It should be noted by GAO
that PRWORA limited HHS's authority and oversight of TANF; hence,
Federal staffing for the program was reduced by 75 percent several
years ago.
Other Comments:
Page 1, first paragraph, sixth sentence (and Appendix I), GAO describes
the work participation rate as "the percentage of a State's adult TANF
recipients who were engaged in work activities during the year." This
is not correct. The work participation rate is based on a ratio of
families, not adults. The annual all families work participation rate
is an average of the 12 monthly all families work participation rates.
The monthly all families work participation rate is a ratio of the
number of families with an adult (or minor child head-of-household) who
are engaged in work divided by the number of families with an adult (or
minor child head-of-household) who are required to participate. This
ratio excludes child-only families and families that are disregarded.
The families that are disregarded from the all families work
participation rate include:
(1) families with a single custodial parent and a child under age one;
(2) families that are required to participate, but are not
participating and are subject to a sanction for the reporting month,
but have not been sanctioned for more than three months within the
preceding 12-month period; (3) families that are part of an ongoing
research evaluation approved under Section 1115 of the Social Security
Act; (4) families that are disregarded based on an inconsistency under
an approved welfare reform waiver that exempts the family; and (5)
families that are disregarded based on participation in a Tribal work
program. Many of these disregarded groups are not mentioned in the
discussion of the calculation and are left out of Figure 1, Appendix 1.
The annual and monthly definitions of the two-parent work participation
rates are similar. These rates include only two-parent families;
however, a two-parent family with a disabled parent is, by statute, not
used in calculating the two-parent rate.
Page 4, first paragraph, sixth sentence, GAO makes a comparison of a
State's work participation rate with a waiver and after the waiver
expired. This is an unfair comparison. Had the waiver not been in
place, some work activities coded under the waiver category would be
permitted under other categories (without changing definitions). Also,
States would have made different decisions about placing recipients in
various work activities. We cannot accurately measure what the work
participation rate would have been absent the waiver when the waiver is
in place.
Appendix 1, it may be useful to add that child-only cases are not
included in the participation rates and that these cases make up about
40 percent of the caseload.
[End of section]
Appendix VI: GAO Contact and Staff Acknowledgments:
GAO Contact:
David Bellis (415) 904-2272:
Staff Acknowledgments:
The following staff members made major contributions to the report:
Gale Harris (Assistant Director), Kathy Peyman (Analyst-in-Charge),
Carolyn Blocker, Amanda Miller, Cady S. Panetta, Tovah Rom, Dan
Schwimer, and Shana Wallace.
[End of section]
Related GAO Products:
Welfare Reform: Rural TANF Programs Have Developed Many Strategies to
Address Rural Challenges. GAO-04-921. Washington, D.C.: Sept. 10, 2004.
Supports For Low-Income Families: States Serve a Broad Range of
Families through a Complex and Changing System. GAO-04-256. Washington,
D.C.: Jan. 26, 2004.
Welfare Reform: With TANF Flexibility, States Vary in How They
Implement Work Requirements and Time Limits. GAO-02-770. Washington,
D.C.: July 5, 2002.
Welfare Reform: Federal Oversight of State and Local Contracting Can Be
Strengthened. GAO-02-661. Washington, D.C.: June 11, 2002.
Welfare Reform: States Are Using TANF Flexibility to Adapt Work
Requirements and Time Limits to Meet State and Local Needs. GAO-02-
501T. Washington, D.C.: Mar. 7, 2002.
Welfare Reform: More Coordinated Federal Effort Could Help States and
Localities Move TANF Recipients with Impairments toward Employment. GAO-
02-37. Washington, D.C.: Oct. 31, 2001.
Welfare Reform: Progress in Meeting Work-Focused TANF Goals. GAO-01-
522T. Washington, D.C.: Mar. 15, 2001.
Welfare Reform: Moving Hard-to-Employ Recipients Into the Workforce.
GAO-01-368. Washington, D.C.: Mar. 15, 2001.
Welfare Reform: Data Available to Assess TANF's Progress. GAO-01-298.
Washington, D.C.: Feb. 28, 2001.
Single Audit: Update of the Implementation of the Single Audit Act
Amendments of 1996. GAO/AIMD-00-293. Washington, D.C.: Sept. 29, 2000.
Welfare Reform: Work-Site-Based Activities Can Play an Important Role
in TANF Programs. GAO/HEHS-00-122. Washington, D.C.: July 28, 2000.
Standards for Internal Control in the Federal Government. GAO/AIMD-00-
21.3.1. Washington, D.C.: Nov. 1999.
Performance Plans: Selected Approaches for Verification and Validation
of Agency Performance Information. GAO/GGD-99-139. Washington, D.C.:
July 30, 1999.
Block Grants: Issues in Designing Accountability Provisions. GAO/AIMD-
95-226. Washington, D.C.: Sept. 1, 1995.
Welfare to Work: JOBS Participation Rate Data Unreliable for Assessing
States' Performance. GAO/HRD-93-73. Washington, D.C.: May 5, 1993.
FOOTNOTES
[1] The fiscal year 2003 work participation rates were the most recent
available rates at the time of our review.
[2] To help determine the elements of internal control to address in
our review, we used GAO, Standards for Internal Control in the Federal
Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999).
[3] Eligibility requirements can include an amount of income that
recipients can earn and still remain eligible for TANF benefits.
Referred to as earned income disregards, these provisions affect
whether recipients who get a paying job can remain eligible for TANF
while they are working.
[4] The current House and Senate TANF reauthorization bills propose to
eliminate the two-parent rate.
[5] For the purposes of this report, the term "adult" refers to TANF
recipients age 20 or over or TANF recipients under age 20 who are head
of a household receiving TANF.
[6] The states that have paid a penalty for not meeting the two-parent
work participation rate are Arkansas, Delaware, Iowa, Mississippi,
Nebraska, New Jersey, New Mexico, North Carolina, Oklahoma, Virginia,
and West Virginia.
[7] As of February 2005, Guam and the Virgin Islands, but no states,
had paid penalties for not meeting the all-family work participation
rate.
[8] Chapter 75 of Title 31, United States Code.
[9] For more information on the Single Audit Act, see GAO, Single
Audit: Update on the Implementation of the Single Audit Act Amendments
of 1996, GAO/AIMD-00-293 (Washington, D.C.: Sept. 29, 2000).
[10] The dollar threshold, currently set at $500,000, for determining
which entities are subject to a single audit is adjusted periodically
by the Director of the Office of Management and Budget.
[11] For more information on separate state programs for two-parent
families, see GAO, Welfare Reform: With TANF Flexibility, States Vary
in How They Implement Work Requirements and Time Limits, GAO-02-770
(Washington, D.C.: July 5, 2002).
[12] States with separate state programs for two-parent families do not
have two-parent families in their TANF program and, therefore, do not
have a two-parent family work participation rate. Also, two-parent
families in a separate state program are not included in the state's
all-family work participation rate.
[13] Officials from California said that they created a separate state
program for two-parent families in order "to study the unique
characteristics and needs of this large and diverse population."
[14] In California, when the adult is sanctioned, the family's monthly
benefit is reduced by the amount of the adult's share. In other states,
the case would be classified as partially sanctioned and would be
removed from the work participation rate calculation for 3 months.
However, after those 3 months, the case would again be counted in the
work participation rate calculation.
[15] We considered the reviews to be timely if they were conducted at
least once a year.
[16] The purpose of the NDNH, maintained by HHS's Office of Child
Support Enforcement, is to provide a national directory of employment
and unemployment insurance information to enable state child support
enforcement agencies to be more effective in locating noncustodial
parents who are responsible for paying child support. State directories
of new hires, state employment security agencies, and federal agencies
provide information to the NDNH.
[17] 45 C.F.R. 265.7(a).
[18] 64 Fed. Reg. 17779 (April 12, 1999).
[19] U.S. Department of Health and Human Services, TANF Program Policy
Questions and Answers, HHS Web site:
http://www.acf.hhs.gov/programs/ofa/polquest/index.htm.
[20] U.S. Department of Health and Human Services, TANF Data Report-
Section One, Disaggregated Data Collection for Families Receiving
Assistance under the TANF Program.
[21] HHS threatened to penalize Pennsylvania for reporting poor quality
work participation data, and in response, Pennsylvania developed a
corrective compliance plan to address its data problems.
[22] Because all states' single audits do not review TANF annually, we
asked state auditors about the most recent single audit that did cover
the TANF program. In some states, this audit was not the most recent
single audit.
[23] In Maryland, the single audit did not test the work participation
data, but other audits did. The auditors identified internal control
weaknesses over the work participation data that, according to state
officials, have since been corrected.
[24] While the most recent single audit for New York did not have
findings related to work participation data, past single audits found
that reported hours lacked documentation to verify that hours reported
were actually worked. The state took corrective action as a result of
these findings.
[25] About one-half the states report using the universe, and about one-
half report using a sample.
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